Cartwright v. State
950 N.E.2d 807
| Ind. Ct. App. | 2011Background
- Cartwright was charged with multiple offenses arising from a December 27, 2008 shooting at the Evansville American Legion, including attempted murder and unlawful firearm possession by a serious violent felon.
- During trial, Tiffany Boyd witnessed Cartwright fire into a crowd; Shaudarekkia Beattie observed Cartwright firing toward her vehicle as well.
- Police later recovered a DNA-consistent shirt and a nine millimeter handgun near a local community center connected to the incident.
- Cartwright was convicted at trial of two counts of attempted battery with a deadly weapon, two counts of attempted aggravated battery, and unlawful possession of a firearm by a serious violent felon, with an aggregate 26-year sentence.
- On appeal, Cartwright challenged the State’s use of a peremptory strike to remove the only African-American juror, and argued the evidence was insufficient to sustain the attempted-battery-with-deadly-weapon convictions.
- The Indiana Court of Appeals reversed the convictions and remanded for a new trial, and addressed sufficiency claims in light of a potential retrial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson challenge success | Cartwright argues the peremptory strike of the only African-American juror violated Batson. | State offered race-neutral explanations for striking the juror but those explanations were pretextual. | Convictions reversed; remanded for a new trial. |
| Sufficiency of evidence for attempted battery with deadly weapon | State failed to prove Cartwright knowingly or intentionally attempted to batter Tiffany and Shaudarekkia. | No weapon-pointing evidence to victims; insufficient mental-state proof. | Sufficient evidence; retrial permitted on these counts. |
Key Cases Cited
- Batson v. Kentucky, 476 U.S. 79 (U.S. Supreme Court 1986) (peremptory challenges cannot be used to strike on the basis of race)
- Jeter v. State, 888 N.E.2d 1257 (Ind. 2008) (three-step Batson inquiry in Indiana)
- Purkett v. Elem, 514 U.S. 765 (U.S. Supreme Court 1995) (race-neutral explanations need not be persuasive at step two)
- McCormick v. State, 803 N.E.2d 1108 (Ind.2004) (prima facie showing of discrimination when only minority juror is struck)
- Highler v. State, 854 N.E.2d 823 (Ind.2006) (removal of minority juror does not alone prove discrimination)
- Miller-El v. Cockrell, 537 U.S. 322 (U.S. Supreme Court 2003) (fact-finder deference in evaluating Batson credibility and intent)